Guidelines

Government information that is particularly influential needs to meet higher
quality standards, and in particular must be reproducible. Per the OMB guidelines,
information is designated as influential if the Department determines that
the information is reasonably likely to have a clear and substantial impact
on public policies or private sector decisions if disseminated. Scientific,
financial, and statistical information all may be considered influential. Individual
programs within the Department of Education may designate certain classes of
scientific, financial, and statistical information as influential.

For example, institutional data on the total number of student borrowers who
enter repayment on Stafford loans during a specific fiscal year, and related
data on the subset of students who default before the end of the next fiscal
year are used in the calculation of cohort loan default rates of Stafford loan
borrowers at each postsecondary institution. These default rates are compared
to established thresholds for high and low default rates, resulting in sanctions
for institutions with high default rates and reduced administrative burden
for institutions with low default rates. Given this use, these data and the
calculations used in computing the rates and in setting the thresholds are
influential. Similarly, the data and formulas used in determining program allocation
of funds in areas such as special education, adult education, and Title I are
influential.

As specified in the OMB guidelines, influential information must be accompanied
by supporting documentation that allows an external user to understand clearly
the information and be able to reproduce it, or understand the steps involved
in producing it. With respect to original and supporting data related thereto,
the Department will assure reproducibility for such data according to commonly
accepted scientific, financial, or statistical standards for that type of data,
taking into account any ethical and confidentiality constraints. In the case
of influential analytic results, the mathematical and statistical processes
used to produce the report must be described in sufficient detail to allow
an independent analyst to substantially reproduce the findings using the original
data and identical methods. In situations where the public cannot access the
data and methods due to other compelling interests such as privacy, intellectual
property or other confidentiality protections, the Department will apply especially
rigorous robustness checks to analytic results and document what checks were
undertaken.